The case confirms that cross-admissibility on a similarity of account basis under s 34P(2)(a) of the Evidence Act 1929 (SA) focuses on the degree of similarity between allegations bearing on the improbability of independent fabrication, rather than the number or regularity of instances of alleged abuse. Differences in the severity or progression of offending between complainants do not deprive common features of their requisite probative value. The sentencing standard in R v D applies notwithstanding the legislative overlay of mandatory minimum non-parole periods for serious repeat offenders under the Sentencing Act 2017 (SA), and the non-parole period that might be imposed should not affect the head sentence through backwards reasoning.
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